Who areLMM Associates? Well, it isn’t a UK-registered company. Rather, it’s sole practitioner Leslie MacLeod-Miller, as his speaker biography in the official brochure for the 2016 annual meeting of the Gaming Regulators European Forum (GREF) shows (screen shot in Figure 1). There Mr MacLeod-Miller, who is a solicitor,describes himself as “a sole practitioner specialising in gaming regulation and compliance”.

His speaker biography finishes: “In the UK gambling regulatory environment he acted as a negotiator with the Department of Media and Sport and the Gambling Commission regarding policy/secondary legislation drafting and implementation, drafting amendments for the House of Commons and the House of Lords.” The same sentence appears in another profile, on the website of firm Ravensbeck Ltd (registered company number: 02037240), where Mr MacLeod-Miller is an “associate”(screen shot in Figure 2).

Mr MacLeod-Miller‘s previous roles include as chief executive of the British Amusement Machine Association (BACTA), a gambling trade association he describes as “the largest gaming lobbying organisation in the UK” (Figure 1).

Political lobbying firms that are members of the Association of Professional Political Consultants (APPC) disclose their political lobbying clients on a public register. The APPC register contemporaneous to the register of interests of MPs’ staff at 15 June 2016, that from 1 June 2016 until 31 August 2016, reveals that LMM Associates was then a client of Interel. (APPC-Register-Aug-2016) (Previous editions of the APPC register are available on the Public Relations and Communications Association (PRCA) website. On 1 November 2018, PRCA and APPC merged. Both were independent member-based bodies, each maintaining its own publicly accessible register of political lobbyists, where members were required to list relevant staff and all clients. There’s now one joint register, available at the PRCA website.)

Thus back in 2016, while working for Mr Hammondin parliament,Ms Stevens had a second job with Mr MacLeod-Miller – who was also using the services of political lobbyist Interel at the same time. Use of a political lobbyist, by definition, indicates the solicitorwanted to engage and influence politicians in parliament.

There’s no suggestion that anyone has done anything illegal. Nevertheless Mr MacLeod-Miller, a solicitor “specialising in gaming regulation and compliance”, was lobbying politicians in parliament. So Ms Stevens‘second job as a “marketing consultant” for the solicitor deserves scrutiny, because of her role as an MP’s member of staff and the privileges it affords.What exactly was Ms Stevens doing for Mr MacLeod-Miller?

Interel acts as the secretariat for the fixed odds betting terminals (FOBTs) all-party parliamentary group (APPG). Mr MacLeod-Miller’s company LM Consultants Ltd (registered company number: 09050186) is listed as an “associate member” of the APPG, and has “contributed more than £1.5k to the running of the group” (screen shot in Figure 3). Mr MacLeod-Miller is owner and sole director, according to Companies House records. Meanwhile, Mr MacLeod-Miller as LMM Associates is also involved with the APPG: he’s identified as such in the minutes of the group’s extraordinary meeting that took place at parliament on 19 March 2018, for example. (FOBT-APPG-Minutes-Extraordinary-Meeting-19.03.18) (The minutes are published on the APPG’s website.)

I emailed Mr MacLeod-Miller for comment at charity Never Such Innocence (registered charity number: 1156148), where he’s chair and a trustee, according to its website. (I couldn’t find a LMM Associates email address for him.) He replied from a LMM Associates address, saying: “Louise was never involved in any business activities or lobbying whatsoever, nor was she at any time client facing and at no time was involved or in contact with Interel. Louise worked for me for a period of time which ended over 2 years ago as my personal [sic] PA (diary management, travel arrangements and typing) for a few hours a week while she was in between jobs and subsequently when she worked part time for Mr Hammond.”

I then went back to Mr MacLeod-Miller for clarification on two points. I first asked whether he really meant “personal PA”. PA is the standard abbreviation for personal assistant. Therefore, “personal” is surely unnecessary in front of PA. Or did he mean something else by PA? For the purposes of my second question, I said I assumed Mr MacLeod-Miller meant personal assistant. I then asked if, as he says, Ms Stevens was his “personal assistant” and performed the tasks he describes, why did she disclose the role on parliament’s register of interests of MPs’ staff as “marketing consultant”?

Having heard nothing a week later, I sent Mr MacLeod-Miller a polite reminder, to which he immediately replied. He wrote: “I have no knowledge of you or how you obtained my e-mail contact. In any case: 1. Matters of employment are private and confidential, and I am not at liberty to make any further comment; 2. I require you to permanently delete my e-mail address from your records in accordance with GDPR regulations; 3. I find your unrequested contact and your previous communications alarming, distressing and unreasonable and believe that your behaviour is calculated to produce such alarm and distress; and 4. You are not to seek to contact me in the future.”

For the avoidance of doubt, I only had MacLeod-Miller’s email address at LMM Associates because he’d sent me a message from it!

I didn’t contact Mr Hammond for comment, after he’d told me not to email again about Ms Stevens (see previous post). Without permission to reach the MP that way, I was thus unable to invite comment from Ms Stevens, too. I couldn’t find a parliament email address for her as an individual, either.

In January 2019, the FOBTs APPG changed its name to the gambling-related harm APPG, following the success of its campaign to reduce the maximum stake on FOBTs from £100 to £2. The stake cut on FOBTs comes into effect on 1 April 2019.

The then former government minister couldn’t have been clearer. My employee “has no association with DLA Piper and works full time in my [parliamentary] office,” said MP Stephen Hammond in an email. He was replying to my query about Marie Stevens, who haddisclosed on parliament’s then latest (at 30 May 2018) register of interests of MPs’ staff her role as a consultant on gambling to the multinational law firm. (register at 30 May 2018) Ms Stevens‘ full name is Marie-Louise Stevens, wrote the senior Conservative MP, but she calls herself Louise Stevens. Yet Mr Hammond‘s answer on DLA Piper obviously begs the question: why hadMs Stevens made such a disclosure on theregister, if, as he says, it’s inaccurate?

In fact, Ms Stevens does(or at least did) have an “association” with DLA Piper.

Mr Hammond wrote in a later email: “Louise worked privately out of working hours on a one-off project [for DLA Piper] which was nothing to do with her work in parliament nor was it advantaged by having a pass. It was placed on the register in error (by Louise who believed any external source of income should be declared, and not just those which are only [sic] advantaged by having a parliamentary pass) and will be removed on its next publication.”

Ms Stevens appears as Marie Stevens on the register, remember. The nameimmediately caught my attention: there‘s a well-known solicitor of that name who has held board positions with bookmakers including Ladbroke Group PLC (now part of GVC Holdings PLC), 888 Holdings PLC and, most recently, Sportingbet PLC. Also, from 1999 until 2004 the same Ms Stevensserved as a member of the Gaming Board for Great Britain, the predecessor to gambling regulator the Gambling Commission. Ms Stevens has been a “regulatory consultant to [the] gaming industry, since 2004”, says her Who’s Who 2019 entry.

When I first wrote to Mr Hammond, I asked whether his employee was the solicitor. The parliamentarian, who was at the time a member of the influential Treasury committee, responded: “She [Louise Stevens]is not and has never been a solicitor. The person to whom you refer may be her mother who I have never met.” I duly wrote back to Mr Hammond saying there’s a need for clarity, I believe, over the relation, if any, between solicitor Marie Stevens and Louise Stevens. Why?Louise Stevens‘disclosed role as a consultant to DLA Piper on gambling.

Soit’s reasonable to ask Mr Hammond whether the solicitor is related to his employee. And if so, how?His statement hadn’t resolved the issue(“may be her mother”). Therefore, I requested a clarification, apologising for prolonging the exchange. I made clear it was the final point; and wasn’t abusive in any way.

Nevertheless the then former government minister didn’t answer the question. Instead Mr Hammond wrote: “I have answered your points fully and clearly. Your last email could fairly be described as harassment. If you persist or publish anything that suggests I have acted improperly I shall report you to the relevant authorities.”

There’s no suggestion that anyone has done anything illegal. But it‘s in the public interest, I believe, to establish whether Louise Stevens is related to solicitor and “regulatory consultant” to bookmakersMarie Stevens, given Louise Stevens‘role as a consultant to DLA Piper on gambling, while working for Mr Hammond in parliament.As everyone knows, there are many controversies around the gambling industry and its regulation. Thus links between parliamentand law firms on gambling should be scrutinised.

Solicitor Marie Stevens didn’t respond to requests for comment. (I used the email address she lists in Who’s Who 2019.)

Then there’s awider point on parliamentand law firms beyond gambling. On 15 January 2017, I exclusively revealedan avoidable conflict of interest that arose for Jake Berry MPbecause of his then second job as a paid consultant to another multinational law firm, Squire Patton Boggs. Mr Berry worked for the law firm from September 2016 until June 2017, beforebecoming a government minister. Here it’s not Mr Hammond who has or had a role with a law firm, of course, but his employee in parliament. But the problem is the same: law firms are opaque and secretive, so it’s always unclear why exactly they’re paying MPs or their staff. And without transparency, there can’t be public trust and confidence.

(For the avoidance of doubt, here transparency is necessary but not sufficient for public trust and confidence.)

DLA Piper didn’t respond to requests for comment. Therefore, not only is the law firm opaque and secretive.It’sunresponsive and unaccountable, too.

On 16 November 2018, Mr Hammond returned to government as health minister.

Here I show why investors should avoid a property developer and investor at whose swanky promotional events the former deputy prime minister Sir Nick Clegg has apparently appeared and spoken. While the firm last year also held a reception at the House of Lords attended by, among others, Jack Straw, the former cabinet minister. Mr Straw gave a speech at the event, according to the company website.

There are photos and videos on the ICC website of Sir Nick at two company events at The May Fair Hotel in central London: one in 2017, the other a year later (screen shot in Figure 1). Also, there used to be photos and a video on the website of the House of Lords event, which took place on 12 April 2018 (screen shots in Figure 2-4). Baroness Doocey, the sponsoring peer for the event, said in an email: “… I was involved with this company for a year from 2017-2018, as an unpaid housing advisor but never received remuneration either in cash or in kind nor did I receive expenses or hospitality.”

Figure 1. Sir Nick Clegg at ICC event, The May Fair Hotel, 2018

Figure 2. Jack Straw at ICC event, House of Lords on 12 April 2018

Figure 3. Jack Straw spoke at ICC event, House of Lords on 12 April 2018

Figure 4. Video of ICC event, House of Lords on 12 April 2018

As I say, photos and a video of the House of Lords event were prominently displayed on the ICC website – until I brought them to the attention of the Yeoman Usher at the Lords, Brigadier Neil Baverstock. ICC breached House of Lords rules by publishing the photos and video on its website. Brigadier Baverstock wrote to Baroness Doocey, asking her to instruct the company to remove the content from its website. This ICC did. But I had to email Brigadier Baverstock again before the firm took down the video from YouTube.

Below follows six reasons investors should avoid ICC.

First, Abbey King Khawaja is “director of government relations” (screen shot in Figure 5). On 24 April 2016, I exposed Mr Khawaja for being an official supporter of the Conservatives – but as a director of a fake company. What’s more, back then his fake company claimed on its website the backing of then Tory prime minister David Cameron! That laughable website disappeared long ago, but there are screen shots in the post. In the second post on the same day, I also revealed Mr Khawaja had somehow succeeded in getting his fake company selected by then government department UK Trade & Investment (UKTI) for its October 2014 market visit to South Africa. An astonishing due diligence failure by UKTI.

Figure 5. Abbey King Khawaja profile: ICC website at 11 May 2018

Second, information on the ICC website about Bobby Singh, “vice president” (screen shot in Figure 6). Mr Singh is “one of the most dynamic and well-respected property entrepreneurs in the UK and internationally”. He’s “held CEO positions for successful property companies such as Harwood Group”. Who they? Well, Mr Singh is owner and sole director of Harwood Group Limited (registered company number: 09658995), which was incorporated on 26 June 2015. Its last publicly available accounts, for 2017, reveal the average number of employees during the year – er, one, as it was in 2016! Further, both sets of accounts to date were submitted late, after Companies House began compulsory strike-off. Not a good sign. (At date of publication Mr Singh is shown as “vice-chairman and founder” on the ICC website.)

Figure 6. Bobby Singh profile: ICC website at 12 May 2018

Third, information on the ICC website about Mark Bloom, a “non-executive director” (screen shot in Figure 7). Mr Bloom is a director of Brighton & Hove Albion Football Club (BHAFC), according to the firm. Yet he isn’t listed as a director on the football club website. Further, Mark Bloom has never been a director of The Brighton & Hove Albion Football Club Ltd (registered company number: 00081077), Companies House records show. However, Tony Bloom is club chair, while his uncle, Ray Bloom, is a director. On 11 February 2019, I requested a comment from BHAFC about the claim on the ICC website. The next day the company removed both the photo and biography of Mark Bloom from its website. He vanished. So what did BHAFC say on 13 February 2019? Head of media & communications, Paul Camillin, wrote in an email: “Following your email we contacted Mr Mark Bloom on this matter. We understand that Imperial Corporate Capital erroneously listed him as one of their directors, and used an inaccurate profile of Mr Bloom, that he neither saw nor approved. We can confirm that Mr Bloom is not a director of Brighton & Hove Albion Football Club, he has never held such a position and he does not present himself as such. We further understand that Imperial Corporate Capital have apologised to Mr Bloom for the error and have removed his profile from their website.”

Figure 7. Mark Bloom profile: ICC website at 11 February 2019

Fourth, Carl Francis, whom ICC refers to as “one of the world’s leading architects” (screen shot in Figure 8), isn’t a registered architect. At date of publication Mr Francis isn’t on the online register of architects published by the UK regulator of architects, the Architects Registration Board (ARB). Only people on the register are legally entitled to use the title “architect” in business or practice. Mr Francis is a “non-executive director” of ICC (screen shot in Figure 9). He also appears as “chief architect” on the website of Imperial Capital IO Limited (registered company number: 11357896), another property investment company in the group (screen shot in Figure 10). Or at least Mr Francis did: the Imperial Capital IO website has vanished. It said: “Buy real estate using cryptocurrency” (screen shot in Figure 11). ICC didn’t respond to emailed requests for comment on the fact Mr Francis isn’t a registered architect.

Fifth, ICC won’t tell me how to invest with it – despite the website saying contact the firm for “more information about our investment offerings”! In December 2018, I emailed ICC twice, asking how to invest. No response. What is the company hiding? Companies House records reveal one way ICC is using investors’ funds: the firm has set up a limited partnership, Imperial Corporate Holdings LP (registered company number: SL026708). ICC is the “general partner”, while investors contributing money do so as a “limited partner”. The limited partnership was registered at Companies House on 13 May 2016. At date of publication there’s nothing about the limited partnership on the ICC website.

One last thing. “Architect” Mr Francis gets around. He’s described as “one of the top 10 architects in the world” on the website of BitRent, which presents itself as a property-related cryptocurrency investment firm (screen shot in Figure 12). BitRent, which says ICC is a partner (screen shot in Figure 13), is a limited partnership – BitRent LP (registered company number: LP018687). The poor English on the website hardly engenders confidence.

Figure 12. Carl Francis, “one of the top 10 architects in the world”: BitRent website at 15 March 2019

Figure 13. ICC is a partner of BitRent: BitRent website at 15 March 2019

ICC is opaque and unresponsive. It has also made false and exaggerated claims. What’s more, the firm isn’t on the FCA financial services register. In short, keep away.

I emailed both Sir Nick and Mr Straw seeking confirmation each had attended the ICC events as shown on the website. Neither had responded by publication time.

There are two serious problems with the last publicly available accounts for a charity controlled and runby a leading IVF specialist. The charityhas failed to address the problems after I brought them to its attention. It has also refused to provide the missing information behind one of the problems. All of my dealings with the IVF specialist and her charity have actually been with her PR firm. How the IVF specialist pays the PR firm, and for what exactly, are central to the problems with her charity’s last accounts. Finally, it’s unclear whether the charity actually does anything.

Prof Geeta Nargund is founder and medical director of CREATE Fertility, a chain of private IVF clinics. Prof Nargund and her firm have received a lot of media attention, not least because they are self-styled pioneers of “natural and mild” IVF. But there’s another reason for the high profile: a PR firm promotes Prof Nargund and CREATE Fertility.

In 2000, Prof Nargundset up charity Create Health Foundation – old name: HER Trust (registered charity number: 1082195).There are currently three trustees.Prof Nargund isn’t a trustee;and to date has never been one. Nevertheless Companies House records indicate she‘s been company secretary to the charitable company since incorporation on 5 January 2000. Further, Prof Nargund is the sole “person with significant control”, according to filings there.

The charity’s last publicly available accounts are made up to 31 December 2017. These show Prof Nargund is also chief executive. They further disclose it spent £56 636 on “charitable activities” during the year, while income was £56 736. What were the charitable activities? A “PR campaign”, which “relates to expenditure incurred on fertility education in schools, national tariff for IVF, welfare of women to be included in the HFE act and low-cost IVF”.

As I say, the role of the PR firm is key to the problems with the last accounts. The first problem concerns the related-party transactions, which are disclosed in note 9 in the notes to the financial statements (screen shot in Figure 1). There the disclosure is incomplete. That is, Prof Nargund’s commercial company, Create Health Limited (registered company number: 04103133), is identified as a related party to the charity. Yet, despite its title, note 9 fails to show the related-party transactions between Create Health Limited and Create Health Foundation.

Figure 1. 2017 accounts: Create Health Foundation

On 13 November 2018, I emailed Prof Nargund via “Beth and Alex” (last names undisclosed), who are identified on the CREATE Fertility website as contact for media queries (screen shot in Figure 2). There I asked the charity to provide the related-party transactions – all of them – between Create Health Limited and Create Health Foundation. Not receiving a response, I sent a second email. This time “Beth” acknowledged receipt. But she didn’t supply the related-party transactions between the two entities, despite further emails.

Figure 2. Media queries: CREATE Fertility website at 13 November 2018

So who are “Beth and Alex”? They’re Beth Farrer and Alex Kane, the two directors of PR firm Farrer Kane Limited (registered company number: 08121122). The two are presumably married: Beth Farrer is Beth Kane at Companies House. She appears as Beth Farrer on the Farrer Kane website, though.

How did I identify “Beth and Alex”, and their company, given the charity’s last accounts don’t refer to either the directors or Farrer Kane? Well, the last accounts for Create Health Limited, made up to 31 March 2018, disclose related-party transactions with the charity: “Create Health Limited made payments to Farrer Kane PR company on behalf of Create Health Foundation of £56 682 (2017: £39 600).” Yet the charity’s last accounts merely identify Create Health Limited as a related party, without disclosing the relevant transactions. Why?

On 28 May 2014, Farrer Kane announced on its website that CREATE Fertility had appointed it “to run its media relations activity in the UK” (screen shot in Figure 3). Thus Farrer Kane has been promoting Prof Nargund’s commercial company for nearly five years.

Remember Create Health Foundation’s 2017 “PR campaign”, organised by Farrer Kane, included “low-cost IVF”. At the same time the PR firm is also promoting Prof Nargund’s low-cost IVF brand, abc ivf. This raises the legitimate question of the extent of the overlap, if any, between Farrer Kane’s work for the IVF specialist’s charity and that for her commercial activities. Charity law requires charities to have only charitable purposes, which must be for the public benefit. A charity must not provide private benefit to anyone, unless the private benefit is incidental.

Then there’s the second problem with Create Health Foundation’s last accounts. They don’t contain an independent examiner’s report to the trustees. An independent examiner is the external person who scrutinises a charity’s accounts. Thus the process of independent examination is essential for public trust and confidence. In January 2019, I twice asked the charity, via Ms Farrer, to explain the omission. No one responded to my emails.

One last thing. For at least two reasons, it’s unclear whether Create Health Foundation actually does anything. First, the trustees write in their latest annual report with the 2017 accounts: “Activity within the charity has been minimal during the year.” What’s more, the same sentence appears in both the 2016 and 2015 trustees’ annual reports! Second, the charity website is very out of date: it still bears the old name, HER Trust (screen shot in Figure 5). The name was changed on 10 May 2013, according to Companies House records. In fact, the website notes the change of name (without a date), saying: “a new website and relaunch are coming soon”. That’s almost six years ago!

Figure 5. Create Health Foundation homepage at 20 March 2019

When asked for comment, a spokesperson for regulator the Charity Commission said in a written statement: “As regulator, we want charities to inspire trust. This includes providing clear information so the public can easily see how a charity is delivering on the good cause they serve. We are aware of concerns regarding Create Health Foundation’s accounts. We will be contacting the trustees to determine our next regulatory steps.”

MIKE LYNCH BACKS LUMINANCE AND DARKTRACE On 18 December 2018, I exclusively exposed Lord Evans of Weardale‘s avoidable conflict of interest after he added yet another paid role – chair of the Committee on Standards in Public Life, ironically enough. The Sunday Times newspaper then reported my analysis, when on the same day Lord Evans made it known he will give up one of his six other posts – as non-executive director of HSBC Holdings PLC (see 30 December 2018 post). Meanwhile, the peer continues as a paid adviser to two linked UK tech start-up companies, Luminance Technologies Ltd and Darktrace Ltd. Both companies use artificial intelligence (AI): Luminance forthe analysis of legal documents; Darktrace for cyber security. Both, too, are backed by British tech entrepreneur Dr Mike Lynch via his venture capital firm, Invoke Capital. Further, Dr Lynch is a director of Luminance and was a director ofDarktraceuntil 30 November 2018. Previously, Dr Lynch was founder and chief executive of Autonomy, the former FTSE 100 tech company. In 2011, Hewlett Packard (HP) bought Autonomy for $11bn. Within a year, however, HP protested strongly at what it perceived as financial impropriety at Autonomy, and wrote off nearly $9bn. Six years later, at the end ofNovember 2018, the US Department of Justice finally charged Dr Lynch with fraud over the sale of Autonomy to HP. The Autonomy founder and former chief executive strongly denies the charges and any wrongdoing. (On ‎30‎ ‎April‎ ‎2018, Sushovan Hussain, Autonomy’s former chief financial officer, was convicted in the US of accounting fraud. Mr Hussain, who wasalso a director of Darktrace,has appealed against his conviction.)

AUTONOMY ALLEGED ACCOUNTING SCANDALAlleged problems with Autonomy‘s accounts are at the heart of the alleged fraud. It’s an alleged accounting scandal. Thus it appears strange for Lord Evans to work for KPMG UK as an independent non-executive, when KPMG UK is one of the so-called Big Four accounting firms (PwC, Deloitte, EY and KPMG).

KPMG DUE DILIGENCE REPORT FOR HP ABOUT AUTONOMY What’s more, KPMG is key to the Autonomy alleged accounting scandal. Prior to the acquisition, HP hired KPMG to do due diligence on the tech firm. Dr Lynch has been publicly citing KPMG’s due diligence report in hisfavour since HP first went public in 2012 with its accusations of accounting fraud at Autonomy. The due diligence report is publicly accessible at a website Dr Lynch maintains, Autonomy Accounts. True, KPMG UK didn’t carry out the due diligence. Nevertheless Lord Evans‘ employer is part of the multinational.

LUMINANCE IS USED BY THREE OF THE BIG FOUR ACCOUNTING FIRMSOn 7 February 2019, Luminance announcedit had secured a further $10m (£7.7m) from its backers, including Invoke Capital. The press release says the legal AI start-up‘s customers include three of the Big Four accounting firms, although it doesn’t name them. This is problematic for Lord Evans, whether or not KPMG UK is one of the three. If KPMG UK uses Luminance, his role as an independent non-executive at the accounting firm would be conflicted.While if KPMG UK doesn’t use it, there’s the risk, actual, potential or perceived, Lord Evans‘ legitimate interest in winning new clients for the start-upmight interfere with his ability to serve as an independent non-executive at the accounting firm.KPMG UK would be an obvious potential customer in such circumstances. (Meanwhile, how many of the Big Four, if any, use Darktrace is unclear.)

BRUNSWICK IS PR FIRM FOR MIKE LYNCH Autonomy hired PR firm Brunswick back in 2011 during the HP takeover. Dr Lynch now uses its services – or at least did at 28 September 2015, according to the Computing website. (https://www.computing.co.uk/ctg/news/2427844/hp-knew-of-autonomys-accounting-practices-before-takeover-according-to-newly-released-documents) Meanwhile, Robert Webb QC, who was chair of Autonomy, is a “senior adviser” at Brunswick(screen shot in Figure 1). He joined the firm in 2016, according to his Who’s Who 2019 entry. It’s an even smaller world: Mr Webb is also chair and directorof Luminance, and chair and director of Darktrace! Thus the two tech companies aren’t linked to Dr Lynch and Autonomymerely because Invoke, which he founded in late 2012, backs them. There’s another connection via Brunswick and Mr Webb. (The Autonomy Accounts website invites questions. In January 2019, I asked via the submission formwhether Brunswick is responsible for the website. I didn’t receive a reply.)

Figure 1. Rob (Robert) Webb QC is a “senior adviser” at Brunswick: company website at 31 January 2019

ERROR IN LUMINANCE LATEST ACCOUNTSLuminance’s latest accounts are made up to 31 December 2017. There note 6, “auditor’s remuneration”, in the notes to the financial statements, fails to disclose the actual figure for auditor’s remuneration (screen shot in Figure 2). Further, there the 2016 figure isn’t stated, either. Why?

Figure 2. 2017 accounts: Luminance Technologies Ltd

UNEXPLAINED LATE FILING OF LUMINANCE LATEST ACCOUNTS Luminance’s latest accounts were due by 30 September 2018. Nevertheless the firm only filed at Companies House on 4 December 2018. There’s no indication in the accounts why the firm submitted so late. In December 2018, I twice emailedEmily Foges, the legal AI start-up‘s chief executive, seeking an explanation. I didn’t receive a response.

AUDITOR INDEPENDENCELuminance picked Alison Seekings at Grant Thornton as independent auditor. Ms Seekings also recently acted asindependent auditor for each of four tech start-up companies linked to Luminance: Darktrace Ltd; Neurence Ltd; Genalys Ltd; and DVL Technology Ltd. These five firms, all backed by Invoke,are linked in various ways. Here I‘m concerned Ms Seekingscould be conflicted as independent auditor because the five companies are linked and so not independent. In other words,there‘s the risk that auditor independence could be compromised. In January 2019,Ms Seekings didn’t respond to emailed requests for comment.

LUMINANCE HASN’T ADDRESSED ERROR IN LATEST ACCOUNTS Also in January 2019, I twice emailed Mr Webb in his capacity as chair and directorof Luminance, requesting comment on the above three issues about the firm’s latest accounts. Again, I didn’t receive a reply.Further,at date of publication the legal AI start-uphas failed to rectify the error in its latest accounts, after I pointed it out in my emails to him.

When asked for comment, Lord Evans said in an email: “As you will have noticed, I am not a director of Darktrace or Luminance nor do I have any executive role with either firm. I am therefore not in a position to comment on the matters that you raise. Nor am I in a position to comment on the litigation that you mention, even if it were proper to do so when it is before the courts, as I have no involvement in it.”